2023 – 004: Cost Allocation of Fringe Benefits to LSC Grants Federal Agency: Legal Services Corporation (LSC) Federal Program Name: LSC Native American Grant Assistance Listing Number: 09.706060 Federal Award Identification Number and Year: 09-706060 - 2023 Award Period: January 1, 2023 – December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: Federal regulations (45 CFR 1630.5 and 2 CFR 200.403) state that expenditures are allowable under an LSC (or federal) grant or contract only if the recipient can demonstrate that the cost was consistent with accounting policies and procedures that apply uniformly to both LSC (or, federal)-funded and non-LSC (of, federal) -funded activities. Condition: During our testing we noted that 100% of medical insurance for a specific location was allocated to the grant. However, we noted that medical insurance for other pay periods and locations were allocated on a trimester basis using an allocation base of total grant hours for the period divided by total general fund hours. As such, the fringe benefit cost mentioned above was allocated in an inconsistent manner to other grant fringe benefit costs was not fully representative of the employees’ time and effort. However, management noted that these costs were allocated in a manner to comply with 45 CFR 1630.5(g) which allows LSC award recipients to allocate proportional share of another funding source’s share of an indirect cost to LSC funds. Questioned costs: None. Context: This single instance was noted during testing of 26 payroll and payroll-related disbursements. Cause: The Organization’s employee benefit cost allocation methodology is primarily based on a periodic calculation of grant hours versus general fund hours multiplied by period costs, but it often includes manual adjustments based on review of individual expense data. Therefore, the methodology is challenging to apply consistently, document contemporaneously, and apply in accordance with federal regulations. Effect: The inclusion of frequent manual adjustments in the Organization’s employee benefit cost allocation methodology could cause costs to be allocated to grants in a manner where costs are not applied uniformly to both LSC (or, federal)-funded and non-LSC (of, federal) -funded activities. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization consider updating its employee benefit cost allocation methodology and process to reduce the frequency of manual adjustments based on review of expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities. Views of responsible officials: There is no disagreement with the audit finding
2023 – 004: Cost Allocation of Fringe Benefits to LSC Grants Federal Agency: Legal Services Corporation (LSC) Federal Program Name: LSC Native American Grant Assistance Listing Number: 09.706060 Federal Award Identification Number and Year: 09-706060 - 2023 Award Period: January 1, 2023 – December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: Federal regulations (45 CFR 1630.5 and 2 CFR 200.403) state that expenditures are allowable under an LSC (or federal) grant or contract only if the recipient can demonstrate that the cost was consistent with accounting policies and procedures that apply uniformly to both LSC (or, federal)-funded and non-LSC (of, federal) -funded activities. Condition: During our testing we noted that 100% of medical insurance for a specific location was allocated to the grant. However, we noted that medical insurance for other pay periods and locations were allocated on a trimester basis using an allocation base of total grant hours for the period divided by total general fund hours. As such, the fringe benefit cost mentioned above was allocated in an inconsistent manner to other grant fringe benefit costs was not fully representative of the employees’ time and effort. However, management noted that these costs were allocated in a manner to comply with 45 CFR 1630.5(g) which allows LSC award recipients to allocate proportional share of another funding source’s share of an indirect cost to LSC funds. Questioned costs: None. Context: This single instance was noted during testing of 26 payroll and payroll-related disbursements. Cause: The Organization’s employee benefit cost allocation methodology is primarily based on a periodic calculation of grant hours versus general fund hours multiplied by period costs, but it often includes manual adjustments based on review of individual expense data. Therefore, the methodology is challenging to apply consistently, document contemporaneously, and apply in accordance with federal regulations. Effect: The inclusion of frequent manual adjustments in the Organization’s employee benefit cost allocation methodology could cause costs to be allocated to grants in a manner where costs are not applied uniformly to both LSC (or, federal)-funded and non-LSC (of, federal) -funded activities. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization consider updating its employee benefit cost allocation methodology and process to reduce the frequency of manual adjustments based on review of expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities. Views of responsible officials: There is no disagreement with the audit finding
2023 – 004: Cost Allocation of Fringe Benefits to LSC Grants Federal Agency: Legal Services Corporation (LSC) Federal Program Name: LSC Native American Grant Assistance Listing Number: 09.706060 Federal Award Identification Number and Year: 09-706060 - 2023 Award Period: January 1, 2023 – December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: Federal regulations (45 CFR 1630.5 and 2 CFR 200.403) state that expenditures are allowable under an LSC (or federal) grant or contract only if the recipient can demonstrate that the cost was consistent with accounting policies and procedures that apply uniformly to both LSC (or, federal)-funded and non-LSC (of, federal) -funded activities. Condition: During our testing we noted that 100% of medical insurance for a specific location was allocated to the grant. However, we noted that medical insurance for other pay periods and locations were allocated on a trimester basis using an allocation base of total grant hours for the period divided by total general fund hours. As such, the fringe benefit cost mentioned above was allocated in an inconsistent manner to other grant fringe benefit costs was not fully representative of the employees’ time and effort. However, management noted that these costs were allocated in a manner to comply with 45 CFR 1630.5(g) which allows LSC award recipients to allocate proportional share of another funding source’s share of an indirect cost to LSC funds. Questioned costs: None. Context: This single instance was noted during testing of 26 payroll and payroll-related disbursements. Cause: The Organization’s employee benefit cost allocation methodology is primarily based on a periodic calculation of grant hours versus general fund hours multiplied by period costs, but it often includes manual adjustments based on review of individual expense data. Therefore, the methodology is challenging to apply consistently, document contemporaneously, and apply in accordance with federal regulations. Effect: The inclusion of frequent manual adjustments in the Organization’s employee benefit cost allocation methodology could cause costs to be allocated to grants in a manner where costs are not applied uniformly to both LSC (or, federal)-funded and non-LSC (of, federal) -funded activities. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization consider updating its employee benefit cost allocation methodology and process to reduce the frequency of manual adjustments based on review of expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities. Views of responsible officials: There is no disagreement with the audit finding
2023 – 009: Cost Allocation of Compensation to Coronavirus State and Local Fiscal Recovery Grants Federal Agency: Department of Treasury Federal Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery, Various – See SEFA Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various – See SEFA Pass-Through Agency: Various – See SEFA Pass-Through Numbers: Various – See SEFA Award Period: Various – see SEFA Type of Finding: Material Weakness in Internal Control over Compliance Other Matters Criteria or specific requirement: Federal regulations (CFR 200.403), state that allowable costs must be consistent with policies and procedures of federal award recipients that apply uniformly to both federally-financed and other activities of the Organization. It also states that costs must be adequately documented. Condition: During our testing, we noted that: We were unable to view evidence for one allocation of $23 of medical insurance expenses for one employee related to one month. Three allocations of medical and dental insurance expenses totaling $1,903 were allocated using the percentage of total grant hours of the period instead of the percentage of total grant salary expense, which was the base used for other similar benefit expense allocations. We were unable to view support of the allocation based on total grant hours for the period. These amounts appeared to be under allocated by $549. One salary allocation of $848 appeared to be under allocated by $1,689 when compared to time and effort records and compensation information. We were unable to see evidence that supported the allocation. As such, the salary costs and fringe mentioned above were allocated in an inconsistent manner to other grant payroll costs were not fully representative of the employees’ time and effort and benefit obtained by grant from the allocated cost. Questioned costs: $23 of allocated medical insurance expense described above, which is related to Assistance Listing Number 21.027 and the Eviction Clinic grant passed through from Arapahoe County. Context: These six instances were noting during testing of 47 payroll and payroll-related disbursements. Cause: The Organization’s salary, wage and employee benefit cost allocation methodology is primarily based on time and effort records and a periodic calculation of grant hours versus general fund hours multiplied by period costs, but it often includes manual adjustments based on review of individual time records and expense data. Management also sometimes allocates employee benefit expense using a base of total grant salary expense for a period when compared to total salary expense for the same period. Therefore, the methodology is challenging to apply consistently, document contemporaneously, and apply in accordance with federal regulations. Effect: The inclusion of frequent manual adjustments and varying allocation bases in the Organization’s salaries, wages, and employee benefit cost allocation methodology could cause costs to be allocated to grants that are not reflective of the time and effort spent on grant activities nor compensation paid to employees during relevant work periods. It would also lead to challenges in maintaining sufficient supporting documentation of such cost allocations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization consider updating its salaries, wages, and employee benefit cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations based on employees’ time and effort records, effective compensation during work periods, and that are calculated in a consistent manner. We also recommend that the Organization maintain contemporaneous documentation supporting all cost allocations. Views of responsible officials: There is no disagreement with the audit finding
2023 – 009: Cost Allocation of Compensation to Coronavirus State and Local Fiscal Recovery Grants Federal Agency: Department of Treasury Federal Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery, Various – See SEFA Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various – See SEFA Pass-Through Agency: Various – See SEFA Pass-Through Numbers: Various – See SEFA Award Period: Various – see SEFA Type of Finding: Material Weakness in Internal Control over Compliance Other Matters Criteria or specific requirement: Federal regulations (CFR 200.403), state that allowable costs must be consistent with policies and procedures of federal award recipients that apply uniformly to both federally-financed and other activities of the Organization. It also states that costs must be adequately documented. Condition: During our testing, we noted that: We were unable to view evidence for one allocation of $23 of medical insurance expenses for one employee related to one month. Three allocations of medical and dental insurance expenses totaling $1,903 were allocated using the percentage of total grant hours of the period instead of the percentage of total grant salary expense, which was the base used for other similar benefit expense allocations. We were unable to view support of the allocation based on total grant hours for the period. These amounts appeared to be under allocated by $549. One salary allocation of $848 appeared to be under allocated by $1,689 when compared to time and effort records and compensation information. We were unable to see evidence that supported the allocation. As such, the salary costs and fringe mentioned above were allocated in an inconsistent manner to other grant payroll costs were not fully representative of the employees’ time and effort and benefit obtained by grant from the allocated cost. Questioned costs: $23 of allocated medical insurance expense described above, which is related to Assistance Listing Number 21.027 and the Eviction Clinic grant passed through from Arapahoe County. Context: These six instances were noting during testing of 47 payroll and payroll-related disbursements. Cause: The Organization’s salary, wage and employee benefit cost allocation methodology is primarily based on time and effort records and a periodic calculation of grant hours versus general fund hours multiplied by period costs, but it often includes manual adjustments based on review of individual time records and expense data. Management also sometimes allocates employee benefit expense using a base of total grant salary expense for a period when compared to total salary expense for the same period. Therefore, the methodology is challenging to apply consistently, document contemporaneously, and apply in accordance with federal regulations. Effect: The inclusion of frequent manual adjustments and varying allocation bases in the Organization’s salaries, wages, and employee benefit cost allocation methodology could cause costs to be allocated to grants that are not reflective of the time and effort spent on grant activities nor compensation paid to employees during relevant work periods. It would also lead to challenges in maintaining sufficient supporting documentation of such cost allocations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization consider updating its salaries, wages, and employee benefit cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations based on employees’ time and effort records, effective compensation during work periods, and that are calculated in a consistent manner. We also recommend that the Organization maintain contemporaneous documentation supporting all cost allocations. Views of responsible officials: There is no disagreement with the audit finding
2023 – 009: Cost Allocation of Compensation to Coronavirus State and Local Fiscal Recovery Grants Federal Agency: Department of Treasury Federal Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery, Various – See SEFA Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various – See SEFA Pass-Through Agency: Various – See SEFA Pass-Through Numbers: Various – See SEFA Award Period: Various – see SEFA Type of Finding: Material Weakness in Internal Control over Compliance Other Matters Criteria or specific requirement: Federal regulations (CFR 200.403), state that allowable costs must be consistent with policies and procedures of federal award recipients that apply uniformly to both federally-financed and other activities of the Organization. It also states that costs must be adequately documented. Condition: During our testing, we noted that: We were unable to view evidence for one allocation of $23 of medical insurance expenses for one employee related to one month. Three allocations of medical and dental insurance expenses totaling $1,903 were allocated using the percentage of total grant hours of the period instead of the percentage of total grant salary expense, which was the base used for other similar benefit expense allocations. We were unable to view support of the allocation based on total grant hours for the period. These amounts appeared to be under allocated by $549. One salary allocation of $848 appeared to be under allocated by $1,689 when compared to time and effort records and compensation information. We were unable to see evidence that supported the allocation. As such, the salary costs and fringe mentioned above were allocated in an inconsistent manner to other grant payroll costs were not fully representative of the employees’ time and effort and benefit obtained by grant from the allocated cost. Questioned costs: $23 of allocated medical insurance expense described above, which is related to Assistance Listing Number 21.027 and the Eviction Clinic grant passed through from Arapahoe County. Context: These six instances were noting during testing of 47 payroll and payroll-related disbursements. Cause: The Organization’s salary, wage and employee benefit cost allocation methodology is primarily based on time and effort records and a periodic calculation of grant hours versus general fund hours multiplied by period costs, but it often includes manual adjustments based on review of individual time records and expense data. Management also sometimes allocates employee benefit expense using a base of total grant salary expense for a period when compared to total salary expense for the same period. Therefore, the methodology is challenging to apply consistently, document contemporaneously, and apply in accordance with federal regulations. Effect: The inclusion of frequent manual adjustments and varying allocation bases in the Organization’s salaries, wages, and employee benefit cost allocation methodology could cause costs to be allocated to grants that are not reflective of the time and effort spent on grant activities nor compensation paid to employees during relevant work periods. It would also lead to challenges in maintaining sufficient supporting documentation of such cost allocations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization consider updating its salaries, wages, and employee benefit cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations based on employees’ time and effort records, effective compensation during work periods, and that are calculated in a consistent manner. We also recommend that the Organization maintain contemporaneous documentation supporting all cost allocations. Views of responsible officials: There is no disagreement with the audit finding
ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES Significant Deficiency in Internal Control Over Compliance and Noncompliance ALN 93.391 – Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Department of Health and Human Services Award Number: NH75OT0000010 Award Year: 2021 Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Uniform Guidance in 2 CFR Section 200.403(g) states that for costs to be allowable under Federal awards, they must be adequately documented. Condition: Controls in place at the City’s Department of Public Health and Environment (DDPHE) were not effective in preventing incorrect expenditures from being charged to the grant. There was one instance where the existence of a control failed to detect an error within an invoice selected, which resulted in an overpayment to the subrecipient. Cause: Personnel reviewing expenditures did not adequately review to ensure invoices were correct prior to payment. Effect or Potential Effect: An invoice to a subrecipient was overpaid. Questioned Costs: $431 Context: BDO selected a sample of 20 expenditures totaling to $216,560 from a population of 162 expenditures totaling to $625,782. There was one expenditure in the amount of $4,101 that was overpaid. The compliance sample was expanded, and another 12 expenditures were selected totaling to $29,975. There were no additional compliance deviations noted. This is a condition identified per review of the City’s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DDPHE should improve existing review controls to ensure the mathematical accuracy of invoices has been checked, especially with respect to payments to subrecipients. Payroll and other costs reported on the face of the invoice should agree to supporting payroll documentation received. Views of Responsible Officials: The City agrees with the finding. DDPHE will implement additional trainings and is encouraging a standard template in Excel to avoid calculation errors. For additional information, see the City’s separate report for planned corrective actions.
Section II – Financial Statement FindingsFinding 2023-001 Significant Deficiency in Internal Controls and Compliance with major program AIL Number: 93.658 Description: Approval of Credit Card Expenditures Criteria: Title 2, CFR, Part 200, Subpart D – Post Federal Award Requirements, section 200.303, Internal controls. states, in part, that “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award…” Title 2, CFR, Part 200, Subpart E - Cost Principles, Basic Considerations, section 200.403, Factors affecting allowability of costs. states, in part, that “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented.” Condition: In our testing we were unable to verify that credit card transactions were tied out to source documents and approval to ensure allowable costs under Uniform Guidance. Cause: Management is not following their policies to reconciling credit card charges to underlying source documents and document approval prior to payments made. Effect: By not reviewing and approving credit card transactions there is a heightened risk of unallowable costs and fraudulent charges. Recommendation: We recommend that management improve internal controls around credit card expenditures by reviewing credit card transactions and underlying receipts and approving prior to payment. Management’s Response: Management’s response to the finding is discussed in the attached Corrective Action Plan. Section III – Federal Award Findings and Questioned Costs Finding 2023-001 Significant deficiency in internal control over compliance with major program AIL Number: 93.658 Program Name: Foster Care Title IV-E Federal Agency: Department of Health and Human Services Pass-through Agency: California Department of Social Services Questioned Costs: None Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles See Finding 2023-01 in Section II above.
FINDING 2023-003 Subject: COVID-19: Coronavirus State and Local Fiscal Recovery Funds - Body Camera - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of the Treasury Federal Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): 71391 Pass-Through Entity: Indiana Department of Homeland Security Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/ Cost Principles, Period of Performance Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 17 CITY OF MICHIGAN CITY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The City's Police Department applied for and was awarded a body camera grant from the Indiana Department of Homeland Security (IDHS). The City's Police Department sought reimbursement from the IDHS in October of 2023. An invoice from Utility, dated October 28, 2022, in the amount of $600,000 for body cameras was submitted for the reimbursement. The invoice was originally paid by the City with American Rescue Plan Act (ARPA) funds on April 3, 2023. The City received reimbursement of $61,740 from the IDHS on December 5, 2023, which was receipted into the City's Grant Fund along with the City's local match in the amount of $30,870. The Controller's Office did an adjustment on December 31, 2023, in the amount of $92,610, to reimburse the ARP Coronavirus LF Recovery Fund and decrease the Grant Fund, for the reimbursement of $61,740 and the local share of $30,870. However, per the grant agreement with the IDHS, "If the subrecipient incurs a financial obligation prior to approval of the State, then the subrecipient will be required to reimburse the State for the amount of funds that were not approved." As such, the expenditure was not an allowable activity or allowable cost and was outside of the period of performance due to the City incurring the expense prior to signing the grant agreement with the IDHS on March 3, 2023. The lack of internal controls and noncompliance were isolated to the purchase noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (c) Be consistent with policies and procedures that apply uniformly to both federallyfinanced and other activities of the non-Federal entity. . . . (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. . . ." 2 CFR 200.306(b) states: "For all Federal awards, any shared costs or matching funds and all contributions, including cash and third-party in-kind contributions, must be accepted as part of the non-Federal entity's cost sharing or matching when such contributions meet all of the following criteria: (1) Are verifiable from the non-Federal entity's records; INDIANA STATE BOARD OF ACCOUNTS 18 CITY OF MICHIGAN CITY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (2) Are not included as contributions for any other Federal award; (3) Are necessary and reasonable for accomplishment of project or program objectives; (4) Are allowable under subpart E of this part; (5) Are not paid by the Federal Government under another Federal award, except where the Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost sharing requirements of other Federal programs; (6) Are provided for in the approved budget when required by the Federal awarding agency; and (7) Conform to other provisions of this part, as applicable." The Grant Agreement states in part: "Any purchases made by the Subrecipient that are not authorized by the U.S. Department of the Treasury allowability guidelines, the Subrecipient's Project or State, will not be reimbursed under this grant." "Pre-award costs, as defined in 2 CFR 200.458, may not be paid with funding from this award." 2 CFR 200.458 states: "Pre-award costs are those incurred prior to the effective date of the Federal award or subaward directly pursuant to the negotiation and in anticipation of the Federal award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. If charged to the award, these costs must be charged to the initial budget period of the award, unless otherwise specified by the Federal awarding agency or pass-through entity." Cause Management had not developed a system of internal controls that would have prevented or detected material noncompliance. The City did not ensure that the policies and procedures in place related to allowable or unallowable activities, allowable costs and cost principles, and period of performance were complied with at the acceptance of the grant from the IDHS. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, an invoice that was previously paid with other federal award funds was submitted for reimbursement to another agency. The original invoice was outside of the period of performance and unallowable as related to the award from the IDHS. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the City. Questioned Costs We identified $61,740 in questioned costs as noted above in the Condition and Context. INDIANA STATE BOARD OF ACCOUNTS 19 CITY OF MICHIGAN CITY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the City establish a proper system of internal controls, including strengthening its policies and procedures to ensure all costs submitted for reimbursement are not already reimbursed by another federal award and are within the period of performance. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Criteria As noted throughout the Uniform Guidance, including Part 2, CFR Part 200.403 notes “Cost must be incurred during the approved budget period.” Condition While performing tests of the Garden’s internal controls over compliance, we noted multiple transactions had occurred after the respective period of performance for the Federal Award had expired. Cause of Condition The Garden has not implemented proper internal control policies to adhere to the requirements of the Uniform Guidance. Effect of Condition Noncompliance may impact future funding from Federal awards. Recommendation We recommend the Garden implement proper internal control procedures to track the period of performance for each Federal Award, and ensure costs are only charged to programs during the proper period.
Criteria As noted throughout the Uniform Guidance, including Part 2, CFR Part 200.403 notes “Cost must be incurred during the approved budget period.” Condition While performing tests of the Garden’s internal controls over compliance, we noted multiple transactions had occurred after the respective period of performance for the Federal Award had expired. Cause of Condition The Garden has not implemented proper internal control policies to adhere to the requirements of the Uniform Guidance. Effect of Condition Noncompliance may impact future funding from Federal awards. Recommendation We recommend the Garden implement proper internal control procedures to track the period of performance for each Federal Award, and ensure costs are only charged to programs during the proper period.
Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: H49MC00119‐19‐00 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2018‐2020 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR sections 200.308 200.309 and 200.403(h)), the Organization may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass‐through entity made the federal award that were authorized by the federal awarding agency or pass‐through entity. Condition: The Organization lacked supporting documentation for non‐payroll expenses. Due to lack of supporting documentation, period of performance could not be verified. Of the sixty (60) nonpayroll transactions examined, ten (10) lacked supporting documentation for review, and 1 expense was for services performed in a prior period. Effect: Management possibly did not expend funds in accordance with the approved detailed lineitem budget and grant agreement and possibly expended funds in the incorrect period of performance. Cause: Expenses including approved invoices and/or supporting documentation were not properly maintained in part due to several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned costs: Known questioned costs of $7,674 and likely questioned costs of $34,117 for Healthy Start. Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all expenses include supporting documentation/invoice indicating period of performance.
Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: H49MC00119‐19‐00 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2018‐2020 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR sections 200.308 200.309 and 200.403(h)), the Organization may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass‐through entity made the federal award that were authorized by the federal awarding agency or pass‐through entity. Condition: The Organization lacked supporting documentation for non‐payroll expenses. Due to lack of supporting documentation, period of performance could not be verified. Of the sixty (60) nonpayroll transactions examined, ten (10) lacked supporting documentation for review, and 1 expense was for services performed in a prior period. Effect: Management possibly did not expend funds in accordance with the approved detailed lineitem budget and grant agreement and possibly expended funds in the incorrect period of performance. Cause: Expenses including approved invoices and/or supporting documentation were not properly maintained in part due to several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned costs: Known questioned costs of $7,674 and likely questioned costs of $34,117 for Healthy Start. Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all expenses include supporting documentation/invoice indicating period of performance.
Unallowable Use of Housing Choice Voucher Cluster Programs’ Funds (Material Weakness, Material Non-Compliance) Section 8 Housing Choice Voucher Program (Housing Choice Voucher Cluster) – Assistance Listing No. 14.871, Emergency Housing Voucher Program (Housing Choice Voucher Cluster) – Assistance Listing No. 14.EHV, Grant Period: Year-End December 31, 2023 Criteria The cost principles in 2 CFR Part 200, Sub-part E of the Uniform Guidance describe allowable and unallowable uses of federal award program subsidies. Parts 200.403 and 200.405 prohibit the use of federal award program subsidies to fund expenditures outside of the applicable federal award program. Specifically, the Section 8 Housing Choice Voucher and Emergency Housing Voucher Programs’ subsidies and reserves cannot be used to fund expenditures and/or deficits of other federal or non-federal programs, except through allowable Management and Book-keeping Fees. Condition and Perspective During 2023, the Authority’s Section 8 Housing Choice Voucher Program advanced $255,941 out of its Program. The Emergency Housing Choice Voucher Program advanced $186,741 out of its Program. Questioned Costs – $255,941 and $186,741 from the Programs. Cause Lack of non-federal funds available to finance non-federal expenditures. Effect Non-compliance with federal Allowable Cost requirements. Recommendation We recommend that the Authority limit advancing funds from the Section 8 Housing Choice Voucher and Emergency Housing Voucher Programs, to allowable Fees only as specified in the Uniform Guidance and applicable HUD literature. Management’s Response The Authority will limit advancing funds from the Section 8 Housing Choice Voucher and Emergency Housing Voucher Programs, to allowable Fees only. The Authority’s Executive Director, Trey George, has assumed the responsibility of executing this corrective action as of November 1, 2024.
Unallowable Use of Housing Choice Voucher Cluster Programs’ Funds (Material Weakness, Material Non-Compliance) Section 8 Housing Choice Voucher Program (Housing Choice Voucher Cluster) – Assistance Listing No. 14.871, Emergency Housing Voucher Program (Housing Choice Voucher Cluster) – Assistance Listing No. 14.EHV, Grant Period: Year-End December 31, 2023 Criteria The cost principles in 2 CFR Part 200, Sub-part E of the Uniform Guidance describe allowable and unallowable uses of federal award program subsidies. Parts 200.403 and 200.405 prohibit the use of federal award program subsidies to fund expenditures outside of the applicable federal award program. Specifically, the Section 8 Housing Choice Voucher and Emergency Housing Voucher Programs’ subsidies and reserves cannot be used to fund expenditures and/or deficits of other federal or non-federal programs, except through allowable Management and Book-keeping Fees. Condition and Perspective During 2023, the Authority’s Section 8 Housing Choice Voucher Program advanced $255,941 out of its Program. The Emergency Housing Choice Voucher Program advanced $186,741 out of its Program. Questioned Costs – $255,941 and $186,741 from the Programs. Cause Lack of non-federal funds available to finance non-federal expenditures. Effect Non-compliance with federal Allowable Cost requirements. Recommendation We recommend that the Authority limit advancing funds from the Section 8 Housing Choice Voucher and Emergency Housing Voucher Programs, to allowable Fees only as specified in the Uniform Guidance and applicable HUD literature. Management’s Response The Authority will limit advancing funds from the Section 8 Housing Choice Voucher and Emergency Housing Voucher Programs, to allowable Fees only. The Authority’s Executive Director, Trey George, has assumed the responsibility of executing this corrective action as of November 1, 2024.
Finding 2023-001 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a)Be necessary and reasonable for the performance of the Federal award and be allocable thereto underthese principles. b)Conform to any limitations or exclusions set forth in these principles or in the Federal award as to typesor amount of cost items. c)Be consistent with policies and procedures that apply uniformly to both federally-financed and otheractivities of the non-Federal entity. d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if anyother cost incurred for the same purpose in like circumstances has been allocated to the Federal award asan indirect cost. e)Be determined in accordance with generally accepted accounting principles (GAAP), except, for stateand local governments and Indian tribes only, as otherwise provided for in this part. f)Not be included as a cost or used to meet cost sharing or matching requirements of any other federallyfinanced program in either the current or a prior period. g)Be adequately documented. h)Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Within a sample of 45, we noted that 25 timecards did not have a documented review. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: Management noted that time is tracked in a spreadsheet and is reviewed but formal documentation of review is not maintained. Questioned Costs: None Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-002 in the prior report. Recommendation: We recommend the Corporation maintain documented approval of all timecards. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-001 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a)Be necessary and reasonable for the performance of the Federal award and be allocable thereto underthese principles. b)Conform to any limitations or exclusions set forth in these principles or in the Federal award as to typesor amount of cost items. c)Be consistent with policies and procedures that apply uniformly to both federally-financed and otheractivities of the non-Federal entity. d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if anyother cost incurred for the same purpose in like circumstances has been allocated to the Federal award asan indirect cost. e)Be determined in accordance with generally accepted accounting principles (GAAP), except, for stateand local governments and Indian tribes only, as otherwise provided for in this part. f)Not be included as a cost or used to meet cost sharing or matching requirements of any other federallyfinanced program in either the current or a prior period. g)Be adequately documented. h)Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Within a sample of 45, we noted that 25 timecards did not have a documented review. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: Management noted that time is tracked in a spreadsheet and is reviewed but formal documentation of review is not maintained. Questioned Costs: None Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-002 in the prior report. Recommendation: We recommend the Corporation maintain documented approval of all timecards. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-001 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a)Be necessary and reasonable for the performance of the Federal award and be allocable thereto underthese principles. b)Conform to any limitations or exclusions set forth in these principles or in the Federal award as to typesor amount of cost items. c)Be consistent with policies and procedures that apply uniformly to both federally-financed and otheractivities of the non-Federal entity. d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if anyother cost incurred for the same purpose in like circumstances has been allocated to the Federal award asan indirect cost. e)Be determined in accordance with generally accepted accounting principles (GAAP), except, for stateand local governments and Indian tribes only, as otherwise provided for in this part. f)Not be included as a cost or used to meet cost sharing or matching requirements of any other federallyfinanced program in either the current or a prior period. g)Be adequately documented. h)Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Within a sample of 45, we noted that 25 timecards did not have a documented review. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: Management noted that time is tracked in a spreadsheet and is reviewed but formal documentation of review is not maintained. Questioned Costs: None Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-002 in the prior report. Recommendation: We recommend the Corporation maintain documented approval of all timecards. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-001 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a)Be necessary and reasonable for the performance of the Federal award and be allocable thereto underthese principles. b)Conform to any limitations or exclusions set forth in these principles or in the Federal award as to typesor amount of cost items. c)Be consistent with policies and procedures that apply uniformly to both federally-financed and otheractivities of the non-Federal entity. d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if anyother cost incurred for the same purpose in like circumstances has been allocated to the Federal award asan indirect cost. e)Be determined in accordance with generally accepted accounting principles (GAAP), except, for stateand local governments and Indian tribes only, as otherwise provided for in this part. f)Not be included as a cost or used to meet cost sharing or matching requirements of any other federallyfinanced program in either the current or a prior period. g)Be adequately documented. h)Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Within a sample of 45, we noted that 25 timecards did not have a documented review. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: Management noted that time is tracked in a spreadsheet and is reviewed but formal documentation of review is not maintained. Questioned Costs: None Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-002 in the prior report. Recommendation: We recommend the Corporation maintain documented approval of all timecards. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-001 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a)Be necessary and reasonable for the performance of the Federal award and be allocable thereto underthese principles. b)Conform to any limitations or exclusions set forth in these principles or in the Federal award as to typesor amount of cost items. c)Be consistent with policies and procedures that apply uniformly to both federally-financed and otheractivities of the non-Federal entity. d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if anyother cost incurred for the same purpose in like circumstances has been allocated to the Federal award asan indirect cost. e)Be determined in accordance with generally accepted accounting principles (GAAP), except, for stateand local governments and Indian tribes only, as otherwise provided for in this part. f)Not be included as a cost or used to meet cost sharing or matching requirements of any other federallyfinanced program in either the current or a prior period. g)Be adequately documented. h)Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Within a sample of 45, we noted that 25 timecards did not have a documented review. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: Management noted that time is tracked in a spreadsheet and is reviewed but formal documentation of review is not maintained. Questioned Costs: None Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-002 in the prior report. Recommendation: We recommend the Corporation maintain documented approval of all timecards. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-001 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a)Be necessary and reasonable for the performance of the Federal award and be allocable thereto underthese principles. b)Conform to any limitations or exclusions set forth in these principles or in the Federal award as to typesor amount of cost items. c)Be consistent with policies and procedures that apply uniformly to both federally-financed and otheractivities of the non-Federal entity. d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if anyother cost incurred for the same purpose in like circumstances has been allocated to the Federal award asan indirect cost. e)Be determined in accordance with generally accepted accounting principles (GAAP), except, for stateand local governments and Indian tribes only, as otherwise provided for in this part. f)Not be included as a cost or used to meet cost sharing or matching requirements of any other federallyfinanced program in either the current or a prior period. g)Be adequately documented. h)Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Within a sample of 45, we noted that 25 timecards did not have a documented review. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: Management noted that time is tracked in a spreadsheet and is reviewed but formal documentation of review is not maintained. Questioned Costs: None Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-002 in the prior report. Recommendation: We recommend the Corporation maintain documented approval of all timecards. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-001 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a)Be necessary and reasonable for the performance of the Federal award and be allocable thereto underthese principles. b)Conform to any limitations or exclusions set forth in these principles or in the Federal award as to typesor amount of cost items. c)Be consistent with policies and procedures that apply uniformly to both federally-financed and otheractivities of the non-Federal entity. d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if anyother cost incurred for the same purpose in like circumstances has been allocated to the Federal award asan indirect cost. e)Be determined in accordance with generally accepted accounting principles (GAAP), except, for stateand local governments and Indian tribes only, as otherwise provided for in this part. f)Not be included as a cost or used to meet cost sharing or matching requirements of any other federallyfinanced program in either the current or a prior period. g)Be adequately documented. h)Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Within a sample of 45, we noted that 25 timecards did not have a documented review. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: Management noted that time is tracked in a spreadsheet and is reviewed but formal documentation of review is not maintained. Questioned Costs: None Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-002 in the prior report. Recommendation: We recommend the Corporation maintain documented approval of all timecards. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
2023-002 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Prior Year Finding Number: N/A Year of Finding Origination: 2023 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Material Weakness and Modified Opinion Federal Agency: U.S. Department of Treasury Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: SLFRP2192; 2021 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations §2 CFR 200.403(a) and §2 CFR 200.403(g) require costs to be necessary and reasonable, and be adequately documented. Condition: The County did not obtain itemized documentation for five out of 22 disbursements tested. The amount of disbursements that did not have supporting documentation totaled $818,036. Questioned Costs: $818,036 Context: The County disbursed funds to cities and towns as non-entitlement units of government (NEU), however; the NEU designation only applies to states providing funds to local governments. The sample size was originally based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing and Single Audits, but was expanded to include four additional payments identified by the County as payments to NEUs. Effect: The County has insufficient documentation to demonstrate expenditures were for allowable activities and met the requirements of allowable costs. Cause: The County believed funds could be disbursed to cities and towns as NEUs. Because of this determination, the County did not obtain itemized support for expenditures incurred. Recommendation: We recommend Chisago County obtain itemized documentation related to grant expenditures to document expenditures were for allowable activities and met the requirements of allowable costs. View of Responsible Official: Acknowledge
Federal Agency: U.S. Department of Human Services Federal Program Name: Medical Assistance (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2305MN5ADM, 2305MN5MAP; 2023 Pass-Through Agency: Minnesota Department of Human Services Compliance Requirement Affected: Eligibility Award Period: Year Ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200.403 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During testing of eligibility requirements, it was noted there are no reviews being completed over MAXIS nor METS casefiles. Questioned Costs: None Context: No supervisor or peer review is being completed over METS and MAXIS casefiles. Cause: Due to staff turnover, the County did not have time to complete the reviews. Effect: Errors made in determining eligibility may not be discovered and benefits may be issued to clients who are not eligible. Repeat Finding: No. Recommendation: We recommend that a supervisor or team lead perform regular internal reviews on MAXIS and METS casefiles to determine that proper policies and procedures are being followed in determining eligibility. Views of responsible officials: There is no disagreement with the audit finding. There is a corrective action plan in place.
Federal Agency: U.S. Department of Human Services Federal Program Name: Medical Assistance (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2305MN5ADM, 2305MN5MAP; 2023 Pass-Through Agency: Minnesota Department of Human Services Compliance Requirement Affected: Allowable Costs/Allowable Activities Award Period: Year Ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: 2 CFR 200.403 lists general criteria for allowability of costs under federal awards, and the 2556 Social Services Fund quarterly report has further guidance on what is allowed to be reported. Condition: During testing of general disbursements, it was noted that for one of the 40 general disbursements tested, costs were not allowable. Questioned Costs: Amount less than $25,000. Context: One of 40 general disbursements tested had costs that are not allowable under program guidance. Cause: Management oversight. Effect: Ineligible costs are reported on the 2556 report. Repeat Finding: No. Recommendation: We recommend that the County continue to be diligent in their review of what is allowable when coding to certain account codes that flow into the DHS reports. Views of responsible officials: There is no disagreement with the audit finding. There is a corrective action plan in place.
Federal Agency: U.S. Department of Human Services Federal Program Name: Medical Assistance (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2305MN5ADM, 2305MN5MAP; 2023 Pass-Through Agency: Minnesota Department of Human Services Compliance Requirement Affected: Reporting Award Period: Year Ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: 2 CFR 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, 2 CFR 200.403 lists general criteria for allowability of costs under federal awards, and the 2556 Social Services quarterly report has further guidance on what is allowed to be reported. Condition: There is no formal review being completed on reports that are required to be submitted to MN DHS. The quarterly 3220 LCTS and annual LCTS Collaborative reports were not reviewed. The annual LCTS Spending Report was submitted after the due date. The County reported $121,563 in disbursements on the 2556 Social Services quarterly report that were funded with other state or federal grants and included no revenue offset in the required line of the report. Questioned Costs: Amount less than $25,000. Context: No formal review is being completed on two of the four quarterly 3220 LCTS reports tested and one of one annual LCTS Collaborative report tested. For one of one annual LCTS Spending report, the report was submitted after the due date and a review was not in place to ensure compliance. Within two of the two 2556 Social Services quarterly reports that were tested, it was found that disbursements funded by other sources were included on the report. Cause: Turnover and lack of review of the requirements of the 2556 instructions by the County. Effect: Ineligible costs are being reported and the reports are not being submitted timely. Repeat Finding: No. Recommendation: We recommend that the County implement review procedures to ensure that the reports are submitted timely and accurately, and record of review is kept on file. Views of responsible officials: There is no disagreement with the audit finding. There is a corrective action plan in place.
Federal Agency: U.S. Department of Human Services Federal Program Name: Medical Assistance (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2305MN5ADM, 2305MN5MAP; 2023 Pass-Through Agency: Minnesota Department of Human Services Compliance Requirement Affected: Eligibility Award Period: Year Ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200.403 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During testing of eligibility requirements, it was noted there are no reviews being completed over MAXIS nor METS casefiles. Questioned Costs: None Context: No supervisor or peer review is being completed over METS and MAXIS casefiles. Cause: Due to staff turnover, the County did not have time to complete the reviews. Effect: Errors made in determining eligibility may not be discovered and benefits may be issued to clients who are not eligible. Repeat Finding: No. Recommendation: We recommend that a supervisor or team lead perform regular internal reviews on MAXIS and METS casefiles to determine that proper policies and procedures are being followed in determining eligibility. Views of responsible officials: There is no disagreement with the audit finding. There is a corrective action plan in place.
Federal Agency: U.S. Department of Human Services Federal Program Name: Medical Assistance (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2305MN5ADM, 2305MN5MAP; 2023 Pass-Through Agency: Minnesota Department of Human Services Compliance Requirement Affected: Allowable Costs/Allowable Activities Award Period: Year Ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: 2 CFR 200.403 lists general criteria for allowability of costs under federal awards, and the 2556 Social Services Fund quarterly report has further guidance on what is allowed to be reported. Condition: During testing of general disbursements, it was noted that for one of the 40 general disbursements tested, costs were not allowable. Questioned Costs: Amount less than $25,000. Context: One of 40 general disbursements tested had costs that are not allowable under program guidance. Cause: Management oversight. Effect: Ineligible costs are reported on the 2556 report. Repeat Finding: No. Recommendation: We recommend that the County continue to be diligent in their review of what is allowable when coding to certain account codes that flow into the DHS reports. Views of responsible officials: There is no disagreement with the audit finding. There is a corrective action plan in place.
Federal Agency: U.S. Department of Human Services Federal Program Name: Medical Assistance (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2305MN5ADM, 2305MN5MAP; 2023 Pass-Through Agency: Minnesota Department of Human Services Compliance Requirement Affected: Reporting Award Period: Year Ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: 2 CFR 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, 2 CFR 200.403 lists general criteria for allowability of costs under federal awards, and the 2556 Social Services quarterly report has further guidance on what is allowed to be reported. Condition: There is no formal review being completed on reports that are required to be submitted to MN DHS. The quarterly 3220 LCTS and annual LCTS Collaborative reports were not reviewed. The annual LCTS Spending Report was submitted after the due date. The County reported $121,563 in disbursements on the 2556 Social Services quarterly report that were funded with other state or federal grants and included no revenue offset in the required line of the report. Questioned Costs: Amount less than $25,000. Context: No formal review is being completed on two of the four quarterly 3220 LCTS reports tested and one of one annual LCTS Collaborative report tested. For one of one annual LCTS Spending report, the report was submitted after the due date and a review was not in place to ensure compliance. Within two of the two 2556 Social Services quarterly reports that were tested, it was found that disbursements funded by other sources were included on the report. Cause: Turnover and lack of review of the requirements of the 2556 instructions by the County. Effect: Ineligible costs are being reported and the reports are not being submitted timely. Repeat Finding: No. Recommendation: We recommend that the County implement review procedures to ensure that the reports are submitted timely and accurately, and record of review is kept on file. Views of responsible officials: There is no disagreement with the audit finding. There is a corrective action plan in place.
Finding No. 2023‐001: Period of Performance – material weakness in internal control over compliance and compliance finding. Continuum of Care Program ALN 14.267 Criteria: As stipulated in 2 CFR Part 200.403(h) of the Uniform Guidance, a cost must be incurred during the approved budget period, unless otherwise authorized by the federal awarding agency or pass‐through entity. Condition: During period of performance testing 1 out of the 14 sample selections was not in compliance with period of performance requirements. Cause: TCHC’s management was not aware that prior authorization from grantor was required to charge expenses from the previous grant period to the new grant period. TCHC had exhausted all the previous grant period funds before the end of the grant period. Effect: TCHC incorrectly charged costs to the grant period beginning December 31, 2023, rather than to the grant period ending November 30, 2023 in accordance with when the costs were incurred. Questioned Costs: None in excess of reporting requirements. Recommendation: TCHC should put internal controls in place to ensure that costs are charged and allocated to the proper grant period. Management’s Response: See corrective action plan.
Finding No. 2023‐001: Period of Performance – material weakness in internal control over compliance and compliance finding. Continuum of Care Program ALN 14.267 Criteria: As stipulated in 2 CFR Part 200.403(h) of the Uniform Guidance, a cost must be incurred during the approved budget period, unless otherwise authorized by the federal awarding agency or pass‐through entity. Condition: During period of performance testing 1 out of the 14 sample selections was not in compliance with period of performance requirements. Cause: TCHC’s management was not aware that prior authorization from grantor was required to charge expenses from the previous grant period to the new grant period. TCHC had exhausted all the previous grant period funds before the end of the grant period. Effect: TCHC incorrectly charged costs to the grant period beginning December 31, 2023, rather than to the grant period ending November 30, 2023 in accordance with when the costs were incurred. Questioned Costs: None in excess of reporting requirements. Recommendation: TCHC should put internal controls in place to ensure that costs are charged and allocated to the proper grant period. Management’s Response: See corrective action plan.
Finding No. 2023‐001: Period of Performance – material weakness in internal control over compliance and compliance finding. Continuum of Care Program ALN 14.267 Criteria: As stipulated in 2 CFR Part 200.403(h) of the Uniform Guidance, a cost must be incurred during the approved budget period, unless otherwise authorized by the federal awarding agency or pass‐through entity. Condition: During period of performance testing 1 out of the 14 sample selections was not in compliance with period of performance requirements. Cause: TCHC’s management was not aware that prior authorization from grantor was required to charge expenses from the previous grant period to the new grant period. TCHC had exhausted all the previous grant period funds before the end of the grant period. Effect: TCHC incorrectly charged costs to the grant period beginning December 31, 2023, rather than to the grant period ending November 30, 2023 in accordance with when the costs were incurred. Questioned Costs: None in excess of reporting requirements. Recommendation: TCHC should put internal controls in place to ensure that costs are charged and allocated to the proper grant period. Management’s Response: See corrective action plan.
Finding No. 2023‐001: Period of Performance – material weakness in internal control over compliance and compliance finding. Continuum of Care Program ALN 14.267 Criteria: As stipulated in 2 CFR Part 200.403(h) of the Uniform Guidance, a cost must be incurred during the approved budget period, unless otherwise authorized by the federal awarding agency or pass‐through entity. Condition: During period of performance testing 1 out of the 14 sample selections was not in compliance with period of performance requirements. Cause: TCHC’s management was not aware that prior authorization from grantor was required to charge expenses from the previous grant period to the new grant period. TCHC had exhausted all the previous grant period funds before the end of the grant period. Effect: TCHC incorrectly charged costs to the grant period beginning December 31, 2023, rather than to the grant period ending November 30, 2023 in accordance with when the costs were incurred. Questioned Costs: None in excess of reporting requirements. Recommendation: TCHC should put internal controls in place to ensure that costs are charged and allocated to the proper grant period. Management’s Response: See corrective action plan.
Finding No. 2023‐001: Period of Performance – material weakness in internal control over compliance and compliance finding. Continuum of Care Program ALN 14.267 Criteria: As stipulated in 2 CFR Part 200.403(h) of the Uniform Guidance, a cost must be incurred during the approved budget period, unless otherwise authorized by the federal awarding agency or pass‐through entity. Condition: During period of performance testing 1 out of the 14 sample selections was not in compliance with period of performance requirements. Cause: TCHC’s management was not aware that prior authorization from grantor was required to charge expenses from the previous grant period to the new grant period. TCHC had exhausted all the previous grant period funds before the end of the grant period. Effect: TCHC incorrectly charged costs to the grant period beginning December 31, 2023, rather than to the grant period ending November 30, 2023 in accordance with when the costs were incurred. Questioned Costs: None in excess of reporting requirements. Recommendation: TCHC should put internal controls in place to ensure that costs are charged and allocated to the proper grant period. Management’s Response: See corrective action plan.
Finding No. 2023‐001: Period of Performance – material weakness in internal control over compliance and compliance finding. Continuum of Care Program ALN 14.267 Criteria: As stipulated in 2 CFR Part 200.403(h) of the Uniform Guidance, a cost must be incurred during the approved budget period, unless otherwise authorized by the federal awarding agency or pass‐through entity. Condition: During period of performance testing 1 out of the 14 sample selections was not in compliance with period of performance requirements. Cause: TCHC’s management was not aware that prior authorization from grantor was required to charge expenses from the previous grant period to the new grant period. TCHC had exhausted all the previous grant period funds before the end of the grant period. Effect: TCHC incorrectly charged costs to the grant period beginning December 31, 2023, rather than to the grant period ending November 30, 2023 in accordance with when the costs were incurred. Questioned Costs: None in excess of reporting requirements. Recommendation: TCHC should put internal controls in place to ensure that costs are charged and allocated to the proper grant period. Management’s Response: See corrective action plan.
Finding No. 2023‐001: Period of Performance – material weakness in internal control over compliance and compliance finding. Continuum of Care Program ALN 14.267 Criteria: As stipulated in 2 CFR Part 200.403(h) of the Uniform Guidance, a cost must be incurred during the approved budget period, unless otherwise authorized by the federal awarding agency or pass‐through entity. Condition: During period of performance testing 1 out of the 14 sample selections was not in compliance with period of performance requirements. Cause: TCHC’s management was not aware that prior authorization from grantor was required to charge expenses from the previous grant period to the new grant period. TCHC had exhausted all the previous grant period funds before the end of the grant period. Effect: TCHC incorrectly charged costs to the grant period beginning December 31, 2023, rather than to the grant period ending November 30, 2023 in accordance with when the costs were incurred. Questioned Costs: None in excess of reporting requirements. Recommendation: TCHC should put internal controls in place to ensure that costs are charged and allocated to the proper grant period. Management’s Response: See corrective action plan.
Finding No. 2023‐001: Period of Performance – material weakness in internal control over compliance and compliance finding. Continuum of Care Program ALN 14.267 Criteria: As stipulated in 2 CFR Part 200.403(h) of the Uniform Guidance, a cost must be incurred during the approved budget period, unless otherwise authorized by the federal awarding agency or pass‐through entity. Condition: During period of performance testing 1 out of the 14 sample selections was not in compliance with period of performance requirements. Cause: TCHC’s management was not aware that prior authorization from grantor was required to charge expenses from the previous grant period to the new grant period. TCHC had exhausted all the previous grant period funds before the end of the grant period. Effect: TCHC incorrectly charged costs to the grant period beginning December 31, 2023, rather than to the grant period ending November 30, 2023 in accordance with when the costs were incurred. Questioned Costs: None in excess of reporting requirements. Recommendation: TCHC should put internal controls in place to ensure that costs are charged and allocated to the proper grant period. Management’s Response: See corrective action plan.
Federal Agency: Department of Justice Federal Assistance Listing Number: 16.756 Program: Court Appointed Special Advocates Award Number: 15JDP-21-GK-02762-CASA Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).” Condition: National CASA/GAL allocated expenditures to programs during 2023 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries), we noted in accordance with §200.403(g) that: • 4 of 60 transactions was partially charged in the incorrect fiscal period, though within the period of performance. The cost of these 4 transactions were $5,246. • 2 of 60 transactions had an error in the allocation rate utilized. The cost of these 8 transactions were $33. • 4 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Known Questioned Costs: $5,279 Likely Questioned Costs: $131,271 Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs in 2023 were $3,612,154. The sample tested consisted of 60 transactions totaling $145,247. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. Identification as a Repeat Finding: 2022-004 and 2022-008. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations, is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that documentation of support and allocation of costs should be maintained. Policies and procedures were enhanced in 2023 and through 2024 to ensure compliance.
Criteria or specified requirement (including statutory, regulatory, or other citation: 2 CFR section 200.303 of the Uniform Guidance requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The 2 CFR section 200.303 indicates that the internal controls required to be established by a non-federal entity receiving federal awards should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. 2 CFR section 200.403 states the following: “Costs must meet the following general criteria in order to be allowable under Federal awards: (a) be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; (b) conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items; (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity; (d) be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost; (e) be determined in accordance with generally accepted accounting principles; (f) not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period; (g) be adequately documented; and (h) cost must be incurred during the approved budget period.” Condition: The New York and Presbyterian Hospital (the Hospital) has processes and internal controls in place to ensure costs submitted to the Federal Emergency Management Agency (“FEMA”) in relation to the Disaster Grants – Public Assistance program were eligible under FEMA’s provisions and were allowable COVID-19-related expenses. These internal controls include ensuring completeness and accuracy of the costs to ensure the costs comply with the terms and conditions of the award. The Hospital’s internal controls did not identify that management inadvertently included certain costs in the FEMA reimbursement submission that were based on the invoiced amounts from a specific vendor that differed from the actual amounts paid by the Hospital. Cause: The Hospital’s internal controls did not identify that management inadvertently included certain costs in the FEMA reimbursement submission that were based on the invoiced amounts from a specific vendor that differed from the actual amounts paid by the Hospital. The difference was due to payment discount provisions utilized in accordance with a previously existing vendor agreement for one specific vendor, resulting in an overstatement of amounts included in the FEMA reimbursement request submitted in the Grants Portal. Additionally, through the Uniform Guidance audit procedures and management’s further review of submitted costs, duplicated items totaling approximately $184,400 were identified within the population of submitted costs. Effect or potential effect: Due to the above, there is a misstatement of the amounts reported in the FEMA reimbursement submission in the Grants Portal resulting in questioned costs of approximately $268,900. Questioned costs: Approximately $268,900, representing the difference between the amounts paid for certain invoices as compared to the amounts incorrectly submitted in the Grants Portal and certain duplicated items. Context: During our testing of FEMA expenditures underlying the grant for FEMA project number 140215, we identified expenditures that were paid at discounted amounts (in accordance with payment terms with a specific vendor) but included in the FEMA reimbursement submission in the Grants Portal at the full invoice amount, without consideration to the discount taken. The invoiced amounts exceeded the actual amounts paid by approximately $84,500. The terms and conditions of the FEMA award require recipients to submit eligible costs incurred limited to the amount paid, thus this issue results in questioned costs. Additionally, through the Uniform Guidance audit procedures and management’s further review of submitted costs, duplicated items totaling approximately $184,400 were identified within the population of submitted costs. The total FEMA expenditures for project number 140215 included on the Hospital’s schedule of expenditures of federal awards is $174.1 million, which includes $16.9 million related to the specific vendor for the payment-related issue described above. The FEMA-obligated amount under this grant is the third obligation for costs that the Hospital submitted to FEMA for reimbursement under this project. The project was initially established through FEMA’s optional expedited funding application and subsequently amended to a streamlined project under FEMA’s provisions; the amendment also extended the grant period beyond the initial ninety-day period of the original application to cover the period through July 1, 2022. The Hospital has adjusted for a portion of the questioned costs in a subsequent claim submission and management has indicated that they will follow this same process for the balance of the questioned cost items. Additionally, management anticipates that any reimbursement revisions, such as for the questioned costs described above, identified related to the third obligated amount will be addressed through the reconciliation of the overall project cost, inclusive of expected payments to the Hospital for additional eligible costs that have been submitted by the Hospital. Identification as a repeat finding, if applicable: The finding is not a repeat finding. Recommendation: Management should correct the cost summary schedule for this project during the reconciliation of the overall project cost, or address in another manner as directed by FEMA. Additionally, management should continue to review on an ongoing basis for similar costs included in the FEMA reimbursement submission for potential submission errors related to discounted amounts. View of responsible officials: Management agrees with the finding.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Allowable Costs/Cost Principles Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): YR 2023 Compliance Requirements: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Condition and Context The County elected to receive the standard revenue loss allowance, allowing it to claim its total COVID-19 - Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation of $4,014,711 as revenue loss to use for government services. As such, all SLFRF program funds to date were expended under the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use category and that recipients' use of revenue loss funds would not give rise to subrecipient relationships as there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. INDIANA STATE BOARD OF ACCOUNTS 17 SULLIVAN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) On May 11, 2021, the Board of County Commissioners passed Ordinance 2021-07 that created a new fund and adopted the American Rescue Plan (ARP). The Ordinance included the procedures for spending the ARP funding which included the following: The Board of County Commissioners will establish the plan, conditions, and rules upon which the funds are to be requested and used. Funds shall be appropriated by the County's fiscal body before use. All expenditure of funds shall be approved by the Board of County Commissioners with any and all claims to be paid from the County's ARP fund. The County Council approved appropriations for all eleven expenditures from the ARP fund in 2023. All eleven expenditures were tested for compliance with the Allowable Costs/Cost Principles compliance requirement. Two of the eleven expenditures, totaling $44,500, did not have adequate supporting documentation to determine the allowability of the cost. In addition, the County did not have written procedures for determining the allowability of costs in accordance with subpart E of 2 CFR 200. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. . . . (g) Be adequately documented. . . ." 2 CFR 200.302(b)states: "The financial management system of each non-Federal entity must provide for the following . . . (7) Written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the Federal award." INDIANA STATE BOARD OF ACCOUNTS 18 SULLIVAN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The lack of internal controls allowed for the County to charge questionable expenditures to the SLFRF program that could be requested to be returned by the Treasury. The County also did not adopt the required written procedures for determining allowability of costs for federal awards. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, costs that were not adequately documented were paid for with federal funds. Questioned Costs Known questioned costs of $44,500 were identified as detailed in the Condition and Context. Recommendation We recommend the County's management establish a proper system of internal controls and develop policies and procedures to ensure costs are allowable for SLFRF award funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Period of Performance Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY 2023 Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context On December 15, 2020, the City entered into a Lease-Purchase agreement with the Crossroads Bank for police and fire radios. On August 28, 2023, the City made a payment of $2,431,243 to the Crossroads Bank to pay the remaining balance due for the police and fire radios from its Coronavirus State and Local Fiscal Recovery Funds (SLFRF) allocation. Per SLFRF program regulations, the period of performance for the SLFRF award began on March 3, 2021, when the funds were disbursed by the grantor agency. All costs must be incurred by December 31, 2024, and funds must be liquidated before December 31, 2026. Although the City's purchase is an eligible purchase under the SLFRF Final Rule, the purchase was initiated and approved by the City prior to the SLFRF period of performance beginning date of March 3, 2021. Further, the project was not prospective in nature, and the City incurred a financial obligation prior to the beginning of the period of performance. As such, the payment of $2,431,243 was determined to be questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 35.5(a) states: "In general. A recipient may only use funds for the purposes enumerated in § 35.6 (b) through (f) to cover costs incurred during the period beginning March 3, 2021, and ending December 31, 2024, subject to the restrictions set forth in sections 602(c)(2) and 603(c)(2) of the Social Security Act, as applicable. A recipient may only use funds for the purposes enumerated in § 35.6 (g) through (h) to cover costs incurred during the period beginning December 29, 2022, and ending December 31, 2024, subject to the restrictions set forth in sections 602(c)(2), 602(c)(5)(C), 603(c)(2), and 603(c)(6)(B) of the Social Security Act, as applicable." 31 CFR 35.3 states in part: ". . . Obligation means an order placed for property and services and entering into contracts, subawards, and similar transactions that require payment. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." Cause Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these polices. The system of internal controls, as designed and implemented by management of the City, was not effective to ensure SLFRF funds were used appropriately. The original date of the contract was not considered when determining the funding source of the payment. Effect Without the proper implementation of an effectively designed system of internal controls, a payment on a debt associated with a project outside of the period of performance occurred. Noncompliance with the provisions of federal statutes, regulations, and terms and conditions of the federal award could result in the loss of future federal funding to the City. Questioned Costs Known questioned costs in the amount of $2,431,243 were identified as noted in the Condition and Context. Recommendation We recommended that management of the City establish a system of internal controls and develop policies and procedures to ensure SLFRF funds are used appropriately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2023-001: Activities Allowed or Unallowed & Allowable Costs/Cost Principles - Material Weakness in Internal Control and Material Noncompliance Repeat of Prior Audit Finding 2022-001 Federal Program: Trans-National Crime Federal Agency: U.S. Department of State - Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2023 Criteria: 2 CFR section 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR sections 200.405 and 200.403(g) require federal awards be expended only for allowable activities and be adequately documented, respectively. Condition/Context: The Corporation was unable to provide a signed contract, payment information, invoice or reconciliation to evidence allowability of the expenditures or documentation of review and approval for the following: • For 3 out of 80 selections, no evidence of approval of the invoice or approval of signed contract could be provided (control). • For 27 out of 80 selections, no evidence of signed contract or payment support could be provided (compliance). This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $24,563. Cause: The Corporation did not retain/could not retrieve the signed contract or any related support for the disbursements due to poor document retention and staffing turnover and did not follow its internal control procedures by including formal, written review of disbursement payments. Effect: The Corporation has not complied with the specific requirements for activities allowed or unallowed and allowable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that the Corporation review its process and implement procedures that would allow management to properly maintain all required documentation on its federal expenditures. Views of Responsible Officials: Over the past year, the Corporation has made significant improvements, reducing the occurrence of these findings compared to 2022. To continue to improve on and address this, the Corporation implemented a new HR solution, Rippling, in 2024, which will ensure all future agreements and rate changes are properly tracked and documented. This system will enhance the Corporation's document retention process and ensure compliance with federal regulations moving forward.
Finding: Allowable Costs/Cost Principles Major program: U.S. Department of Homeland Security Federal Assistance Listing Number: 97.036 - COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) Passed through New York State Division of Homeland Security and Emergency Services, Pass-through entity identifying number 542653 Criteria or specific requirement: According to § 200.403(f) of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, allowable costs must “not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period” Condition: During the year ended December 31, 2023, Village Center for Care was granted project funding under the FEMA Public Assistance grant program in response to the COVID-19 public health emergency. A total of $1,934,664 of FEMA assistance payments were received from the pass-through entity, New York State Division of Homeland Security and Emergency Services. The eligible expenses that were obligated and disbursed for FEMA funding were incurred between March 2020 and January 2021, during which some of the expenses were also eligible for and reimbursed by other federal sources of funding and other previous FEMA projects. It was discovered that a total of $199,590 of COVID-19 eligible expenses (i.e. contract labor and supplies) that were reimbursed by other federal sources of funding and other previous FEMA projects were duplicative of those reported as project obligations to the FEMA project funding granted to Village Center for Care in 2023. Questioned costs: $199,590 Context: The entire population of $1,934,664 of FEMA expenditures reported on the current year schedule of expenditures of federal awards was compared against previously reimbursed COVID-19 funding that Village Center for Care has received. From this review of the entire population, 48 expenditures in the population were found to have been previously reimbursed by other federal sources totaling $199,590. Effect: Village Center for Care reported certain expenses in this FEMA project application that were previously reimbursed by other federal sources of funding and other previous FEMA projects. Cause: Prior to submitting this project application to FEMA, the Village Center for Care accounting department aggregated the total amount of eligible expenses available to be used for their FEMA projects as well as for other federal funding sources and determined that there were more expenses than the total award amounts that they received. However, they did not identify that expenses which were already reimbursed by other federal sources of funding and other previous FEMA projects were also included in this FEMA project funding. As a result there was duplicative submission of certain expenses. Identification as a repeat finding: This is not a repeat finding. Recommendation: We recommend that Village Center for Care not only look at total expenses that are allowable for use under multiple federal sources of funding but should also review the expenses at a detailed level to ensure that individual expenses are not double counted. Views of responsible officials and planned corrective actions: Village Center for Care agrees with the recommendation that expenses should be reviewed at a detailed level to ensure that individual expenses are not double counted. See separate auditee document for planned corrective action.
2023-002 – SIGNIFICANT DEFICIENCY – Claims Payments Made Based on Incorrect Calculations of Amounts to be Reimbursed (Originated in 2022) U.S. Department of Treasury – Passed through the State of Alabama Department of Treasury – COVID 19 Coronavirus State and Local Fiscal Recovery Fund – ALN #21.027 – Program Year 2023 Criteria – Per 2 CFR Subpart E - 200.403(a) and (b), allowable costs under federal award programs must be necessary and reasonable for the performance of the federal award and must conform to any limitations or exclusions set forth in the federal award as to types or amounts of cost items. In addition, per 2 CFR Subpart E – 200.405(a), a cost is allocable to a particular federal award if the goods or services involved are chargeable or assignable to that federal award in accordance with relative benefits received. Finally, per CFR 200.303(a), non-federal entities are required to establish and maintain effective internal controls over federal awards. Condition – For 1 of 60 disbursements sampled, reimbursed claims amounts included un-allowable costs due to the reimbursement calculations being performed incorrectly in the determination of the appropriate reimbursement amount. Cause – As a result of the Foundation’s reliance solely on certifications received, amounts were not appropriately disbursed under the federal award program. Effect – Claims payments included amounts that were not chargeable or assignable to the federal award in accordance with relative benefits received. Questioned Costs – $95,663 known questioned costs (total amounts paid based on incorrect reimbursement calculations), $529,835 likely questioned costs – amount extrapolated to entire population based on % of known questioned costs. Auditor’s Recommendation – Policies and procedures should be designed, implemented, and monitored which ensure that detailed supporting documentation is obtained and reviewed for all disbursements in accordance with federal award requirements. In addition, all calculations of amounts to be reimbursed should be appropriately recalculated to ensure the proper amount is included in the claims payments. Management response and current status – See management corrective action plan
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Foster Care – Title IV-E Assistance Listing Number: 93.658 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 2301MNFOST Federal Award Identification Number and Year: 2301MNFOST, 2023 Compliance Requirement Affected: Activities Allowed/Allowable Costs Award Period: Year Ending December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: 2 CFR 200.403 lists general criteria for allowability of costs under federal awards, and the Social Services Fund Quarterly Expense Report (2256) also has further guidance on what can be reported. Condition: For 1 of 40 disbursements tested, it was noted the costs were not allowable. Questioned Costs: $620. Context: Auditor tested one warrant coded to the DHS Social Services Fund Quarterly Expense Report (2256) that fell in a category explicitly excluded from allowability according to the report instructions. Cause: Level of invoice detail and client's understanding of the instructions for what can be coded. Effect: Ineligible costs could be reported. Repeat Finding: No. Recommendation: We recommend that the County continue to be diligent in their review of what is allowable when coding to certain account codes that flow into the DHS reports. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. The County will continue to be diligent in their review of what is allowable when coding to certain account codes that flow into the DHS reports.
(3) Federal Award Findings and Questioned Costs: Finding Number: 2023-001 Program: COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Federal Agency Name: Federal Emergency Management Agency Federal Award Number: N/A Federal Award Year: 2023 Federal Assistance Listing Number: 97.036 Compliance Requirement: Criteria Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Further, Subpart E Section 200.403 states that costs must be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for. Conditions Found In one of 25 selections for testwork over allowability of costs, expenditures related to inventory were submitted for reimbursement to FEMA at an incorrect value. Further, as the expenditures were not properly reviewed, this is an instance of the District’s internal control not operating as designed. Cause The District does not have adequate processes and controls in place to ensure that all inventory expenditures submitted for reimbursement by FEMA under the COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) program are priced accurately. Effect Without effective controls in place, expenditures could be reimbursed by the program that are considered unallowed or are not at appropriate values, resulting in non-compliance with program requirements. Questioned Costs $21,437, representing the known amount of expenditures incorrectly reimbursed by COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) program. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This finding is not a repeat finding in the immediate prior audit. Recommendation We recommend that management strengthen processes and controls in place to ensure all inventory expenditures submitted to FEMA for reimbursement under the COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) program are appropriately reviewed prior to submission to ensure they are allowable and priced accurately. Views of Responsible Officials The District agrees with the finding and accepts the recommendation.
Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Medical Assistance Program, COVID-19 Block Grants for Prevention and Treatment of Substance Abuse ALN: 93.778, 93.959 Award period: July 1, 2022 – June 30, 2024 Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented. Additionally, the 2 CFR Part 200.430 requires that charges to Federal awards for salaries and wages must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Employee benefits expenditures charged to the programs do not agree to supporting documentation, such as employee benefit provider premiums invoices. Additionally, the pay rate paid to an employee was different from their approved pay rate. Lastly, an employee received eight hours of birthday pay (as allowed under ABHS’s personnel policies) in two different pay periods. Context: Nine of 25 employee benefit expenditures tested did not agree with employee benefit provider premium invoices. One of 25 employees tested was paid at a rate different from their approved pay rate. One of 25 employees tested received eight hours of birthday pay in two different pay periods. Questioned Costs: $358 for the Medical Assistance Program and $0 for the COVID-19 Block Grants for Prevention and Treatment of Substance Abuse program. Cause: The employer portion of employee benefit premiums are preloaded into the accounting system each year to be allocated to the different business units/programs at ABHS. ABHS does not have a process in place to subsequently reconcile these expenditures to the employer benefits provider premium invoices and/or employee benefit election forms. There was also a lack of review of approved pay rates and leave requests during 2023. Effect: ABHS may not be able to demonstrate that the costs charged to federal programs are allowable. Auditor’s Recommendations: ABHS should implement a reconciliation process to ensure that employee benefit expenditures charged to federal programs agree with employee benefit provider premiums invoices and/or employee benefit election forms.41 Management’s Response: ABHS acknowledges the finding related to employer benefits. As a corrective measure, we have initiated a comprehensive review of our current systems and identified key areas that require immediate upgrades. With the adoption of these upgrades, ABHS will perform an interim review of the expenditures recorded in the accounting system compared to the invoices.
Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Medical Assistance Program, COVID-19 Block Grants for Prevention and Treatment of Substance Abuse ALN: 93.778, 93.959 Award period: July 1, 2022 – June 30, 2024 Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented. Additionally, the 2 CFR Part 200.430 requires that charges to Federal awards for salaries and wages must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Employee benefits expenditures charged to the programs do not agree to supporting documentation, such as employee benefit provider premiums invoices. Additionally, the pay rate paid to an employee was different from their approved pay rate. Lastly, an employee received eight hours of birthday pay (as allowed under ABHS’s personnel policies) in two different pay periods. Context: Nine of 25 employee benefit expenditures tested did not agree with employee benefit provider premium invoices. One of 25 employees tested was paid at a rate different from their approved pay rate. One of 25 employees tested received eight hours of birthday pay in two different pay periods. Questioned Costs: $358 for the Medical Assistance Program and $0 for the COVID-19 Block Grants for Prevention and Treatment of Substance Abuse program. Cause: The employer portion of employee benefit premiums are preloaded into the accounting system each year to be allocated to the different business units/programs at ABHS. ABHS does not have a process in place to subsequently reconcile these expenditures to the employer benefits provider premium invoices and/or employee benefit election forms. There was also a lack of review of approved pay rates and leave requests during 2023. Effect: ABHS may not be able to demonstrate that the costs charged to federal programs are allowable. Auditor’s Recommendations: ABHS should implement a reconciliation process to ensure that employee benefit expenditures charged to federal programs agree with employee benefit provider premiums invoices and/or employee benefit election forms.41 Management’s Response: ABHS acknowledges the finding related to employer benefits. As a corrective measure, we have initiated a comprehensive review of our current systems and identified key areas that require immediate upgrades. With the adoption of these upgrades, ABHS will perform an interim review of the expenditures recorded in the accounting system compared to the invoices.
Finding 2023-002 Significant deficiency in internal controls over compliance related to period of performance. Federal Agency: Department of Health and Human Services Program Title: Unaccompanied Alien Children Program Assistance Listing Number: 93.676 Award Numbers: 90ZU0339/03 and 90ZU0587/01 Project Period: February 1, 2022 - October 31, 2023 and November 1, 2023 - October 31, 2024 Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. Any costs incurred before the federal awarding agency or pass-through entity made the federal award, must be authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). Condition/Context for Evaluation During the audit for the year ending December 31, 2023, we noted four instances out of 40 where the Organization charged costs to the grant that were outside of the period of performance for the related award. Questioned Costs 90ZU0339/03 - $995 90ZU0587/01 - $408 Cause The Organization’s internal controls were not sufficient to ensure proper cutoff of grant expenditures and the allocation to the related award. Effect or Potential Effect Unallowable costs were charged to the grant. Repeat Finding Not Applicable. Recommendation We recommend that management develop internal controls for appropriate cutoff of grant expenditures and review to ensure the appropriate costs were charged to the budgeted period to the grant. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying management corrective action.
Finding 2023-002 Significant deficiency in internal controls over compliance related to period of performance. Federal Agency: Department of Health and Human Services Program Title: Unaccompanied Alien Children Program Assistance Listing Number: 93.676 Award Numbers: 90ZU0339/03 and 90ZU0587/01 Project Period: February 1, 2022 - October 31, 2023 and November 1, 2023 - October 31, 2024 Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. Any costs incurred before the federal awarding agency or pass-through entity made the federal award, must be authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). Condition/Context for Evaluation During the audit for the year ending December 31, 2023, we noted four instances out of 40 where the Organization charged costs to the grant that were outside of the period of performance for the related award. Questioned Costs 90ZU0339/03 - $995 90ZU0587/01 - $408 Cause The Organization’s internal controls were not sufficient to ensure proper cutoff of grant expenditures and the allocation to the related award. Effect or Potential Effect Unallowable costs were charged to the grant. Repeat Finding Not Applicable. Recommendation We recommend that management develop internal controls for appropriate cutoff of grant expenditures and review to ensure the appropriate costs were charged to the budgeted period to the grant. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying management corrective action.